CITING its principle of “benevolent neutrality” in resolving disputes between the State and the Church, the Supreme Court (SC) has ruled that the Philippine Postal Corp. (PhilPost) did not violate the Constitution when it allowed the printing and sale of more than 1.2 million postage stamps to commemorate the 100th founding anniversary of Iglesia ni Cristo (INC) in 2014.
In a 26-page ruling penned by Associate Justice Noel Tijam, the Court en banc affirmed the July 24, 2015, decision and the resolution dated March 8, 2016, of the Court of Appeals (CA), which declared PhilPost’s use of public funds to print the commemorative stamps did not violate Section 29 (2) Article VI of the Constitution which bars the use of public funds to support a religious sect.
Tijam recently retired, after the ruling was issued.
“The printing of the INC commemorative stamp is no different. It is simply an acknowledgment of INC’s existence for a hundred years. It does not necessarily equate to the State sponsoring the INC,” the Court ruled.
In Estrada v. Escritor, the Court ruled that “benevolent neutrality recognizes the religious nature of the Filipino people and the elevating influence of religion in society; at the same time, it acknowledges that [the] government must pursue its secular goals.”
The policy, according to the Court, gives room for accommodation of religious exercises as required under the Constitution.
Thus, the Court said, when asked to determine whether there has been a violation of the provision on separation of the Church and the State, it has adopted a stance of “benevolent neutrality.”
“Rightfully so, for this incorporates the Constitutional principle of separation of the Church and the State while recognizing the people’s right to express their belief or nonbelief of a Supreme Being,” the SC averred.
The Court did not give weight to the argument of petitioner Renato Peralta that the printing and issuance of the INC commemorative stamp involved disbursement of public funds and smacks of sponsorship of religious activities, thus, violating the principle of separation of powers between the State and the Church, and the non-establishment of religion clause.
Peralta, who filed the suit in his capacity as taxpayer, insisted that printing and issuance of INC commemorative stamps constitute free advertisement for the INC at the expense of taxpayers’ money.
PhilPost printed a total of 1.2 million stamps although the memorandum of agreement between INC and PhilPost covered only 50,000 pieces, he noted.
However, the Court held that the printing of the INC commemorative stamps did not breach the non-establishment or religion clause.
It said the costs for the printing and issuance of the 50,000 stamps were all paid for by INC. “Any perceived use of the government property, machines or otherwise, is de minimis [about minimal things] and certainly do not amount to a sponsorship of a specific religion,” the SC said.
The court also saw no violation of the constitutional prohibition on the establishment of religion with regard to the remaining 1,150 pieces of commemorative stamps printed and distributed by PhilPost.
It noted that PhilPost has also issued stamps for the Catholic Church, such as those featuring heritage churches, the International Eucharistic Congress and Pope Francis.
It also printed in the past stamps celebrating 300 years of Islam.
“Based on the foregoing, this Court is not convinced that PhilPost has actually used its resources to endorse, nor encourage Filipinos to join INC or observe the latter’s doctrines. On the contrary, this Court agrees with the respondents that the printing of the INC commemorative stamp was endeavored merely as part of PhilPost’s ordinary business,” the Court said.
It shot down Peralta’s claim of an illegal disbursement of funds under Section 29 (2) of Article VI of the Constitution.The records, according to the Court, do not show that the State has been using the resources and manpower of PhilPost for INC’s advantage.